UNITED STATES OF AMERICA v. HINDA OSMAN DHIRANE
US Court of Appeals for the Fourth Circuit, Niemeyer, July 16, 2018,
Foreign Intelligence Surveillance Act (FISA) – The FISA rule allowing a challenged order to be reviewed by the trial judge alone without defense review is constitutional even though it does not allow “an open, adversarial proceeding” on whether or not a Franks hearing is required.

Material Support of Terrorists – To commit this crime, a defendant must:
(1) knowingly provide material support (or attempt/conspire to do so)
(2) to a foreign terrorist organization
(3) that the defendant knew had been designated a foreign terrorist organization or had engaged in terrorism

Material Support of Terrorists – “Material Support or resources” is defined as “any property… or service… except medicine or religious materials.”

Material Support of Terrorists – For the exception related to contribution of “medicine or religious materials” to apply, these materials must be given directly. Giving money that may be used to obtain these supplies is insufficient to fall into the exception.

From the Case: Material support “given to a terrorist organization to promote ‘peaceable’ or ‘lawful’ conduct furthers terrorism as it ‘frees up other resources within the organization that may be put to violent ends.'”